12. Provision of Funding
12.1.1
Members recognize their responsibility to support worthwhile activities both within and outside their communities.
12.1.2
Members must ensure that there are no incentives to prescribe, recommend, dispense, purchase, supply, approve, reimburse or administer a product in exchange for any form of funding.1
[[1]]Members should establish clear written criteria for the review and approval of funding requests. Such criteria should include a determination of whether the funding request is reasonable in light of activity being funded.[[1]]
12.1.3
Support cannot be provided to an individual Stakeholder or to an entity that is controlled in fact by an individual Stakeholder or its family member, legal representative or agent with the exception of:
- Sponsorship of an individual Health Care Professional or Other Stakeholder to attend an international conference or meeting event (in accordance with Section 10.2) or
- In the case of investigator-initiated studies where the individual Stakeholder is the investigator of the study.2
[[2]]This Section is not intended to restrict the provision of compassionate use or patient assistance programs where the patient is the direct beneficiary of the support.[[2]]
12.1.4
A written rationale and clear objective consistent with the Guiding Principles of this Code should accompany all requests for funding.3 When accepting a request for funding, Members must document the nature of funding provided in a written agreement.
[[3]]Requests should also include a detailed budget or breakdown itemizing how the requested support will be used in order to assess the appropriateness of funding.[[3]]
12.1.5
Funding must be clearly acknowledged in accordance with Section 3.4.1.
12.1.6
Funding must not be provided in a way that can undermine the independence of the recipient.
12.1.7
Members should conduct appropriate due diligence to ensure that recipients: (i) are appropriate and reputable; and (ii) have the capacity and skills to undertake the funded activity. Members must not influence the use or implementation of the support beyond general requirements to ensure that it is used in accordance with the written agreement between the Member and the recipient.
12.2Donations and Grants
12.2.1 Definition
12.2.1.1
Donations are provisions of funding or in-kind contributions to support health care in general, local communities, or other charitable and philanthropic activities. The Member Company does not control or influence the support provided or acquire a tangible benefit.
12.2.1.2
Grants are provisions of funding to support independent bona-fide scientific, medical, or health care-related activities (undertaken for educational, informational or research purposes), where the Member Company does not control, influence or participate in the design or conduct of the activity or acquire a tangible benefit from the funding.4
[[4]]A mere display of the Member Company’s logo or name is not considered a benefit and is acceptable. Corporate brand promotion though (banner, logo placement on event promo materials) is not appropriate for grants/donations.[[4]]
12.2.1.3
Grants are provided in response to an unsolicited request from eligible organization, while donations may be solicited.5
[[5]]Members may not approach institutions or individuals and encourage or solicit them to apply for grants. However, Members can provide donations to organizations without a request.[[5]]
12.2.2 Standards
12.2.2.1
Donations, including donations in kind, may only be provided to not-for-profit organizations and registered charities involved in conducting activities such as artistic, charitable, cultural, community, educational, humanitarian, health, philanthropic, and sporting endeavours. In accordance with Section 12.1.3, donations must not be provided to private medical practices or clinics.
12.2.2.2
Grants may be provided to groups or associations of Stakeholders to organize bona-fide activities such as medical research, public policy research, continuing professional education, and training or to support any project that will enhance patient outcomes or relates to, patient or community education or community projects that promote better health care. Grants must not be provided to hospitals, private medical practices/ clinics or academic societies, or professional associations or organizations for routine operational costs.6
[[6]]Requests for grants must include all details (such as a budget, learning objectives (where applicable)) of the funding requested to ensure there are no operational, capital, lease or salary expenses included in such requests. Requests from medical practices/private clinics for project funding (including salary expenses) may only be agreed to by the Member if the project is distinct from the ongoing operations of the entity; of limited duration, and the associated project expenses are not otherwise reimbursable. This Section is not intended to restrict the provision of operational funding to registered charities, patient organizations and other public not-for-profit organizations.[[6]]
12.2.2.3
Grants and Donations must not be provided for, nor directed to promotional purposes and must not be disguised promotion. Acknowledgement by the recipient organization of such support must be restricted to an appropriate statement of support and follow the guidance frameworks for promotion provided by Health Canada.7
[[7]]See the Distinction between Advertising and other Activities Policy, Health Canada
https://www.canada.ca/en/health-canada/services/drugs-health-products/regulatory-requirementsadvertising/policies-guidance-documents/policy-distinction-between-advertising-activities.html[[7]]
12.3Sponsorships
12.3.1 Definition
Sponsorships are provisions of funding or in-kind contributions to support bona-fide scientific, medical, healthcare-related or other activities (undertaken for education, informational, research or related purposes), where the Member company may control, influence or participate in the design or conduct of the activity or acquire a tangible benefit.8 Sponsorships may be solicited or unsolicited and may include programs, projects, or activities.9
[[8]]8 Benefits may include tangible items (e.g., entry tickets, table booth or floor space, prominent print or online corporate logo placement) as well as the opportunity to build corporate reputation and recognition for the Member company (e.g., supporting Women’s Leadership event, supporting global initiative on environment sustainability etc.).[[8]]
[[9]]Sponsorships of conferences and congresses are covered under Section 10 of the Code.[[9]]
12.3.2
12.3.2.1
Sponsorships are provided to organizations involved in educational, health related, scientific or medical activities.
12.3.2.2
Members may provide financial or non-financial support to registered charities and/or not-for-profit organizations through the sponsorship of a fundraising activity, which may include the purchase of a table or tables at a dinner or other social event, the purchase of a foursome at a golf tournament, or other sporting or cultural activity. Individuals invited by Members to attend such fundraising activities may be Stakeholders other than Health Care Professionals, their spouses and/or administrative staff.
12.3.2.3
It is recognized that Members may not have an active role and participation in the sponsored program, project or activity. Members could sponsor an activity initiated by an organization without having any shared responsibility for the delivery of the activity; however, with the expectation to receive a tangible benefit.
12.3.2.4
The program/project objectives, purpose of the sponsored activity and defined benefit to the Member must be clearly articulated and documented in a written agreement. In addition, Members’ contribution, whether financial or in kind must be clearly acknowledged and accurately reflected in the terms of the written agreement.
12.4Journal Clubs and Rounds
12.4.1 Definition
Journal clubs and rounds are activities during which HCPs exchange information on related scientific and clinical issues. These activities take place in a variety of formats including lectures, debates, panel discussions or simulations to achieve particular learning objectives and are non-promotional in nature.
12.4.2 Standards
12.4.2.1
All support provided to journal clubs and rounds must be provided exclusively in the form of a grant. Members must ensure that support is provided in accordance with Sections 12.1 and 12.2.
12.4.2.2
The recipient organization may use the grant to pay for expenses including speaker honoraria, meals and refreshments, or travel and accommodation in relation to a journal club or round. However, Members cannot pay these expenses separately from the funding provided.
12.4.2.3
Members must only sponsor journal clubs and rounds that take place in an appropriate setting conducive to learning, such as a hospital, a clinic or an academic institution.
12.4.2.4
Member employees may attend journal clubs and rounds, as long as they are permitted by the institution organizing the activity. Member sales representatives can attend these activities only as observers; they cannot participate in the discussion. Member employees cannot detail products, provide samples, or set up any booth at a journal club or round.